Dear
All,
The
Registries Stakeholder Group [RySG] would like to
propose a friendly amendment to the Vertical Integration Charter circulated
by Stéphane.
For purposes
of accuracy and consistency, we believe that Objective #4 should be revised
to read: “To identify and clearly
articulate the differences between the current restrictions and practices
concerning registry-registrar separation and equivalent
access, on the one hand, and the options described in the most recent
version of the DAG and supporting documents and changes considered by staff, on
the other hand.”
The words
“equivalent access” in yellow would replace the words “equal access” that
are in the current version of Objective #4. We understand that the Charter
Group has recognized the difference between “equal access” and “equivalent
access” in its deliberations and has adopted “equivalent access” in other
parts of the Charter.
More
generally, the RySG notes
that the proposed working definitions in the Charter are neither accurate
nor complete and, in certain cases, they represent policy statements.
The RySG underscores the importance of developing standalone definitions for
each element of vertical integration. However, these definitions
should be developed by experts in competition and antitrust matters and
derived from, where possible, language in ICANN contracts and ICANN
documentation that uses the relevant terms.
Many
thanks.
Kind
regards,
Caroline.